Privacy Policy

Privacy Policy — xtracker.ai

Last Updated: April 2026

1. Introduction

This Privacy Policy ("Policy") sets forth the practices of xtracker.ai ("Company," "we," "us," or "our") regarding the collection, use, disclosure, and protection of personal information obtained through the use of our mobile application and associated services (collectively, the "Services").

Users are encouraged to read this Policy carefully. By accessing or using the Services, you acknowledge that you have read and understood this Policy. If you do not agree to the terms herein, you should discontinue use of the Services immediately.

2. Information We Collect

The Company collects the following categories of personal information in connection with the provision of the Services:

2.1 Location Data

Precise geolocation data, including GPS coordinates and network-based location information, is collected for the purpose of providing core tracking functionality.

2.2 Device Information

Technical information including device model, operating system version, and device identifiers, is collected to ensure compatibility, security, and service performance.

2.3 Account Information

Email address and account credentials necessary for account creation and authentication. Payment transactions are facilitated through certified third-party payment processors. The Company does not retain full payment card details.

2.4 Usage and Diagnostic Data

Application usage logs and diagnostic data, including crash reports, are collected for the purposes of service maintenance, performance monitoring, and quality improvement.

3. Purpose of Processing

The Company processes personal information solely for the following purposes:

• To provide, operate, and maintain the tracking and geofencing functionalities of the Services
• To deliver location-based alerts and notifications as configured by the user
• To ensure the security, integrity, and performance of the Services
• To respond to technical support and customer service inquiries
• To fulfill applicable legal and regulatory obligations

The Company does not sell personal information to third parties under any circumstances.

4. Legal Basis for Processing

Applicable to users located in the European Economic Area (EEA):

The Company relies on the following legal bases for the processing of personal data, as provided under the General Data Protection Regulation (GDPR):

• Performance of a Contract. Processing is necessary for the delivery of core tracking and geofencing services as requested by the user.
• Consent. Processing of precise location data is conducted on the basis of the user's explicit consent. Users may withdraw consent at any time by modifying device-level location permissions or by submitting a request to support@xtracker.ai. Withdrawal of consent shall not affect the lawfulness of processing conducted prior to such withdrawal.
• Legitimate Interests. Processing conducted for the purposes of service security, fraud prevention, and service improvement, where such interests are not overridden by the rights and interests of the data subject.
• Legal Obligation. Processing necessary to comply with applicable laws and regulatory requirements.

5. Disclosure of Information

The Company does not sell, rent, or trade personal information. Disclosure of personal information may occur only in the following limited circumstances:

• Service Providers. Personal information may be disclosed to third-party vendors, including cloud infrastructure and payment processing providers, engaged to support the delivery of the Services. All such providers are bound by appropriate confidentiality and data protection obligations.
• Legal and Regulatory Compliance. Personal information may be disclosed where required by applicable law, judicial order, or lawful request by governmental or regulatory authorities.
• Protection of Rights and Safety. Personal information may be disclosed where reasonably necessary to protect the rights, property, or safety of the Company, its users, or the public.
• Corporate Transactions. Personal information may be disclosed in connection with a merger, acquisition, reorganization, or sale of assets, subject to appropriate notice being provided to affected users.

6. Data Security

The Company implements technical and organizational measures designed to protect personal information against unauthorized access, disclosure, alteration, or destruction. Such measures include, but are not limited to, encryption of data in transit utilizing TLS 1.3 protocol, encryption of data at rest utilizing AES-256 standard, and role-based access controls and authentication requirements.

The Company acknowledges that no method of electronic transmission or storage can guarantee absolute security. In the event of a data breach involving personal information, the Company shall notify affected users and relevant authorities in accordance with applicable legal requirements.

7. Children's Privacy

The Services are not directed toward children under the age of thirteen (13). Where the Services are utilized for the purpose of family or parental monitoring, the following conditions apply:

Verifiable parental or legal guardian consent is required prior to the collection of any personal information relating to a minor. Parents and legal guardians retain the right to access, correct, or request the deletion of their child's personal information at any time. Collection of a minor's data may be discontinued upon written request submitted to support@xtracker.ai or through the account management settings.

The Company operates in compliance with the Children's Online Privacy Protection Act (COPPA) and applicable international equivalents.

8. Rights of Data Subjects

Subject to applicable law, individuals whose personal information is processed by the Company are entitled to exercise the following rights against the Company:

• Right of Access. To request confirmation of whether personal data is being processed and to obtain a copy thereof.
• Right to Rectification. To request correction of any inaccurate or incomplete personal data held by the Company.
• Right to Erasure. To request the deletion of personal data, subject to applicable legal limitations and obligations.
• Right to Restriction. To request that the processing of personal data be limited to specific purposes in certain circumstances provided by law.
• Right to Object. To object, on grounds relating to a particular situation, to processing conducted based on the Company's legitimate interests.
• Right to Data Portability. To receive personal data in a structured, commonly used, and machine-readable format, and to transmit such data to another controller where technically feasible.

All requests to exercise the aforementioned rights should be submitted in writing to support@xtracker.ai. The Company shall acknowledge and respond to verified requests within thirty (30) days of receipt. The Company reserves the right to require reasonable proof of identity prior to processing any such request.

California Residents. Pursuant to the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), California residents are further entitled to request a disclosure of personal information collected, to request the deletion thereof, and to opt out of the sale or sharing of personal information. The Company affirms that it does not sell or share personal information for advertising or any other commercial purpose.

9. International Transfers of Personal Data

Personal data collected by the Company may be transferred to, and processed in, jurisdictions outside the user's country of residence, including the United States and member states of the European Union. Where such transfers are subject to legal requirements, the Company implements appropriate safeguards, including Standard Contractual Clauses as approved by the European Commission, to ensure an adequate level of data protection.

10. Amendments to This Policy

The Company reserves the right to amend this Policy at any time. In the event of material changes, affected users shall be notified via in-application notification or electronic mail prior to the changes taking effect. Continued use of the Services following such notification shall constitute acceptance of the amended Policy.

11. Contact Information

Inquiries regarding this Policy, or requests to exercise data subject rights, should be directed to the following:

• Email: support@xtracker.ai
• Company: [Legal Entity Name]
• Registered Address: [Registered Business Address]